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People are talking
Why all GE foods
should be labeled
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October 23, 2002
Governor John A. Kitzhaber, M.D.
State Capitol Building
900 Court Street, NE
Salem, Or 97301
Dear Governor Kitzhaber:
This letter explains why Consumers Union (publisher of Consumer
Reports) supports Measure 27, the ballot initiative that would require
mandatory labeling of foods and food additives produced using genetic
engineering sold in Oregon, or produced in Oregon.
First and foremost, consumers have a fundamental right to know
what they are eating. Many laws, at the federal, state and even
local level, are designed to inform consumers of facts they want
to know about food. These include laws that require labeling of
juice made from concentrate, milk that is homogenized, imported
food as to its country of origin, food that is frozen or irradiated,
as well as ingredients and additives. All these foods are regarded
as safe by the US Food and Drug Administration. However, this information
is required to be given to consumers at the point of purchase because
consumers care and want to know about these aspects of food. With
this information, they are able to make informed choices for themselves
and their families.
Second, we believe, based on our research, that there are clear
differences between foods that are genetically engineered and foods
that are not, and these differences are significant to many consumers.?
Genetically engineered foods are foods developed and produced using
recombinant DNA technology, rather than traditional breeding techniques.
Recombinant DNA technology adds to or alters genetic material in
a laboratory that could not be added through normal plant or animal
breeding. As examples, this material includes bacterial genes that
code for antibiotic resistance, which serve as “marker”
genes, and viral genes that “turn on” introduced genetic
material. Other commonly introduced genes include a bacterial gene
that causes a plant to produce a substance toxic to insect larvae
and a bacterial gene that makes the plant invulnerable to herbicides.
It may be FDA’s opinion that these differences are not “significant,”
but many consumers regard them as very significant and have told
the agency so via tens of thousands of comments to FDA Federal Register
notices.
The differences between a genetically engineered potato and a traditionally
bred potato are arguably greater than the differences between a
frozen potato and a fresh one, or between an Oregon potato and the
same variety grown in Canada. Under current law, the last two facts
have to appear on the label. Consumers have a right to know about
all these differences.
With regard to safety, while none of the genetically engineered
foods currently on the US market have been shown to be unsafe for
human consumption, we are deeply concerned that the federal government
does not adequately insure or test for safety to consumers and the
environment. The US regulatory system for such foods is a patchwork
with serious gaps and weaknesses. For example, FDA, the nation’s
primary food safety agency, relies solely on a voluntary consultation
process with the developer to assure human and environmental safety--which
puts the basic responsibility for public safety on the companies
developing the products. We think this is far too lax a process
for such a new technology. Many critical data have not been gathered
under this system.
Moreover, it is not even mandatory for a company to inform the
FDA when a newly engineered variety of food is going on the market.
Given the rapid globalization of the food supply, we are concerned
that genetically engineered foods could be grown in foreign countries
with no safety assessment systems at all and be legally sold in
the US. The Oregon initiative would at least require such foods
to be labeled.
A critical question in a safety assessment is whether a genetically
engineered food poses a risk of an allergic reaction. A gene that
produces an allergen could be transferred from one food to another.
For example, when scientists introduced a Brazil nut gene into soybeans
to improve its protein content, the engineered soy turned out to
cause an allergic reaction in Brazil-nut-sensitive individuals.
While this product was never commercialized, it illustrated that
this problem can easily occur. There is also a question about whether
newly introduced proteins that have never been in the diet before
could turn out to be allergenic. Labels could help health professionals
identify such a problem.
We thus disagree with the thrust of the letter sent to you on October
4, 2002, by FDA Deputy Commissioner Lester M. Crawford. Unlike FDA,
we think the differences between genetically engineered food and
non-engineered traditional foods are significant. We believe that
FDA should have required labeling of genetically engineered food
as a material fact under the Food Drug and Cosmetic Act. Indeed,
several years ago more than 50 members of Congress sent a letter
to the FDA Commissioner agreeing that genetic engineering is a material
fact under the FDCA.
Further, we think labels could promote public health since they
would result in government agencies becoming aware of genetically
engineered foods grown in other countries that may not have gone
through any safety assessment process. In addition, such labels
could help health professionals identify any unexpected effects
that might have been missed in the company’s voluntary consultation
with FDA, in the same way that health professionals identify unexpected
difficulties with FDA-approved pharmaceutical products.
Based on the experience of the twelve countries of the European
Union that have instituted mandatory labeling of genetically engineered
food, we anticipate that the impact on consumer food prices will
be negligible
A mandatory labeling law in Oregon could have benefits in terms
of agricultural exports. Not only European countries, but also,
Japan, South Korea, China, Australia and New Zealand all have mandatory
labeling requirements, and a labeling law would put Oregon in a
good position to sell products in those markets.
There is ample legal precedent for Measure 27, such as Proposition
65 in California, which mandated labeling of any consumer products
that contained a substance found to cause cancer in animal tests.
At the bottom line, however, the consumer is entitled to make an
informed choice about buying genetically engineered food, and without
such labels, they are in the dark.
We hope you will find these views useful and will support Measure
27.
Sincerely,
R. David Pittle, Ph.D., Senior Vice President, Technical Policy
Jean Halloran, Director, Consumer Policy Institute
Michael K. Hansen Ph.D., CPI Research Associate, Consumers Union
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